- When data is submitted, measures should be taken to verify the:
- beneficial owner;
- ownership or control relationship between the beneficial owner and the entity;
- person making the declaration.
- This should be done by:
- ensuring values conform to known and expected patterns;
- cross-checking information against existing authoritative systems and other government registers; and
- checking supporting evidence against original documents.
- After data has been submitted, it should be pro-actively checked to identify potential errors, inconsistencies, and outdated entries, using a risk based approach where appropriate, requiring updates to the data where necessary.
- Mechanisms should be in place to raise red flags, both by requiring entities dealing with BO data to report discrepancies and by setting up systems to detect suspicious patterns based on experience and evidence.
- Ownership types that are difficult or impossible to verify (e.g. bearer shares) should be prohibited.
To maximise the impact of BO registers, it is important that users and authorities can trust that the representation of ownership in a register reflects the true reality of who owns or controls a particular company. Verification is a combination of checks and processes that help ensure that BO data is accurate and complete at a given point in time. Checks can be deployed at different stages in a declaration system with the aim of making data high quality and reliable in order to create confidence in a register and to maximise its utility and impact.
This OO Principle is particularly relevant in the following aspects of implementation. These correspond to steps in our Implementation Guide.